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Raymond M. Gauvreau

Associate
he/they
rgauvreau@rc.com
Portrait of Raymond M. Gauvreau
Portrait of Raymond M. Gauvreau

Raymond M. Gauvreau

Associate

he/they
rgauvreau@rc.com
Hartford, CT — 860.275.8316

Raymond M. Gauvreau focuses his practice on insurance coverage advice and disputes and extra-contractual litigation. He also assists with appeals and the defense of class actions. Ray’s insurance coverage experience includes the representation of property and liability insurance carriers in connection with high-exposure litigation that often involve extra-contractual claims for damages.

Ray has assisted in the defense of Covid-19 coverage matters both at the trial and appellate level in state and federal courts and has participated in the defense of putative class action lawsuits involving commercial and homeowner’s insurance. He has experience in litigating matters across the federal and state courts of Connecticut from the pre-suit stage up to mediation or trial. Ray understands that no two cases are alike and does all he can to identify a client’s business objectives in order to secure the best possible outcome. He is a member of the firm’s Insurance + Reinsurance group.

In addition to his coverage work, Ray has experience in insurance defense, products liability, anti-SLAPP litigation, and has provided guidance on a number of education and employment law matters. Ray also has experience handling pro bono prisoners’ rights matters. Before entering private practice, he served as a legal research law clerk for the judges of the Connecticut Superior Court, where he was based in the Judicial District of Litchfield at Torrington. 

  • University of Connecticut School of Law (Juris Doctor)
    • Managing Editor of the Connecticut Journal of International Law, Volume 33
    • Hastie Moot Court Champion, Fall 2016
    • CALI Award for Excellence in Employment Law and Suing the Government
    • Connecticut Bar Association Labor and Employment Award
  • Central Connecticut State University (Bachelors, magna cum laude)
    • B.A., Political Science
    • Honors Program Graduate

  • State of Connecticut
  • U.S. District Court, District of Connecticut

Robinson+Cole Pro Bono Award, 2024

Connecticut Bar Association (2018)
Treasurer, Insurance Section (2024)

Experience

Litigation: Favorable Resolutions of Extracontractual Claims

Prepared motions to dispose of extracontractual claims from complaints in state and federal court that led to quick, favorable resolutions of said claims or the overall case either through a voluntary withdrawal or settlement.

Litigation: Special Investigative Issues

Advised insurance companies with regard to special investigative issues and how said investigations could impact coverage.

Litigation: Business Income Claim

Advised insurance company with respect to a property damage, business income, contingent business income claim stemming from significant snowstorm.

Publications

November 25, 2025

1st Circ. Offers Diversity Jurisdiction Lessons For Assignees

Law360 Expert Analysis

Practitioners know that in order to bring a diversity action in federal court, the amount in dispute must exceed the statutory minimum and there must be complete diversity of citizenship between the plaintiffs and defendants. Assignments can complicate this analysis because Title 28 of the U.S. Code, Section 1359, provides in relevant part that "[a] district court shall not have jurisdiction of a civil action in which any party, by assignment or otherwise, has been improperly or collusively made ... to invoke the jurisdiction of such court." An Oct. 16 opinion from the U.S. Court of Appeals for the First Circuit in Gore and Associates Management Co. v. SLSCO Ltd. serves as a cautionary tale about what can go wrong — dismissal after years of litigation — if an assignee invoking the jurisdiction of the federal courts has not alleged sufficient facts, or created a sufficient record, to demonstrate there is complete diversity between not only the parties to the action, but also between the putative assignors and parties on the counterparties to the assignee.[1] Background On July 6, 2019, the plaintiff Gore and Associates filed a diversity action in the U.S. District Court for the District of Puerto Rico against the defendant SLSCO and its surety, Hartford Fire Insurance Co., for alleged breach of contract, failure to pay a third-party bond claim, and a payment bond claim under the Puerto Rican Little Miller Act.[2] Specifically, Gore alleged that SLSCO failed to pay invoices submitted by Gore's nonparty subcontractors — Earthwrx LLC, Uniify of Puerto Rico LLC and Uniify Strategic Business Solutions LLC — under several federal contracts related to rebuilding projects in Puerto Rico and the U.S. Virgin Islands after 2017's Hurricane Maria. In the complaint, Gore alleged that its subcontractors assigned their respective rights under the aforementioned invoices to Gore. Preappeal Trial Court Proceedings The defendants moved to dismiss on the ground that the plaintiff's action violated a valid contractual forum selection clause, for failure to state a claim under Rule 12(b)(6) of the Federal Rules of Civil Procedure, and, in the alternative, sought a stay of any surviving claims pending completion of contractually mandated mediation proceedings, but did not challenge the court's subject matter jurisdiction pursuant to Rule 12(b)(1). The trial court dismissed without prejudice certain subcontract-related claims, but refused to dismiss claims under two specific bonds and the Little Miller Act. The district court thereafter instructed Gore to file the dismissed claims in the appropriate forums and return to this case once those claims had been disposed. The case was then stayed. Gore sought reconsideration, leave to amend their complaint and to lift the stay, but the district court denied the requested relief and an appeal followed. Diversity Issue Arises On appeal, the First Circuit sua sponte noted that the while the complaint alleged that Gore was assigned rights by Earthwrx and the Uniify entities, the record did not provide sufficient information to determine whether there was subject matter jurisdiction. As such, the First Circuit ordered the parties to provide supplemental submissions and specifically ordered Gore to provide information about the citizenship of each alleged assignor. The parties complied with the First Circuit's order to file supplemental submissions. Gore posited that the court had adequate diversity jurisdiction. In so contending, it represented that, upon information and belief, Earthwrx was wholly owned by 541 LLC, an Oregon limited liability company with a principal place of business in Oregon. Gore also represented, again upon information and belief, that Uniify of Puerto Rico, a Puerto Rican entity, was wholly owned by Uniify Strategic Business Solutions LLC, a Louisiana company. However, Gore did not submit any evidence to support its position. Unsatisfied, the First Circuit remanded the case for jurisdictional fact-finding, specifically directing the district court to determine: (1) whether each individual subcontractor was completely diverse from the defendants and, if not; (2) whether the assignments to Gore were a collusive attempt to manufacture diversity jurisdiction in violation of Section 1359. Remand Proceedings On remand, the parties agreed to exchange written discovery and reserved the right to take depositions, but no party requested an evidentiary hearing and, instead, they opted to submit simultaneous briefs with accompanying evidence on the jurisdictional issues. In support of the contention that diversity jurisdiction exists for Earthwrx, Gore submitted a certificate of formation, allowing the district court to find that Earthwrx was a Puerto Rican company and James A. Young and Bobby Owens were listed as authorized persons, administrators and members of the LLC. The court determined that none of this information was helpful in assessing whether there was complete diversity between Earthwrx and the defendants. More problematic was that this evidence contradicted Gore's prior submission to the First Circuit that suggested Earthwrx was solely owned by 541 LLC. No documentation was provided to the district court regarding 541 LLC. While Gore did submit some additional public documentation obtained regarding property purchased by Earthwrx's members, it was plainly hearsay and unauthenticated. An email chain was also submitted, but there was no context for the statements therein, even though, according to Gore, its purported purpose was to show that the assignments were to consolidate claims, avoid unnecessary litigation costs and avoid inconsistent judgments. As for the Uniify entities, the court was only able to determine that Uniify was created on Nov. 18, 2017; that Terry Bee was listed as the president, administrator and authorized person for the LLC; and that Uniify Strategic was determined to be an inactive Louisiana LLC that included Bee and Joseph P. Meyer as officers. These findings once again conflicted with Gore's prior position before the First Circuit as it had previously reported that Uniify of Puerto Rico was wholly owned by Uniify Strategic, which, according to the district court, militated against Gore's position. As it had regarding Earthwrx, Gore submitted several additional documents that also ran afoul of the Federal Rules of Evidence in that they were inadmissible hearsay, unauthenticated, unreliable, speculative, inconsistent and simply not helpful to assessing diversity as of the date the action was filed. Outcome Given the foregoing, the U.S. District Court for the District of Puerto Rico was unable to accomplish the First Circuit's remand directive and could not analyze whether there was complete diversity between any of the alleged assignors-subcontractors and defendants — much less turn to the second question of examining the motive behind a particular assignment if there was not complete diversity between any particular assignor-subcontractor and the defendants. The First Circuit held that this was fatal to Gore's suit because it bore the burden of demonstrating the validity of the assignments, as the party seeking to invoke diversity jurisdiction. While Gore sought another remand to conduct additional discovery and seek an evidentiary hearing, the First Circuit refused to do so because Gore had already been given two opportunities to provide evidence of diversity and allowed seven months for the exact purpose of conducting discovery and seeking an evidentiary hearing. The case was dismissed. Key Lessons for Assignees Seeking to Invoke Diversity Jurisdiction If an assignee plans to invoke the diversity jurisdiction of a federal court, it cannot rely solely on the diversity of the parties to the action (if first filed in state court) or eventual action. Instead, the assignee ought to conduct a rigorous investigation into the citizenship of each and every assignor whose rights the assignee is asserting prior to bringing an action. Furthermore, assuming an assignor is an LLC, it is incumbent on the assignee to investigate the citizenship of all members of such entity.[3] If the members of a particular LLC are themselves unincorporated associations, then a deeper, iterative investigation is required; the citizenship of any member must be traced through "however many layers of members or partners there may be," according to the First Circuit's 2023 decision in BRT Management LLC v. Malden Storage LLC.[4] Assuming there is complete diversity of citizenship between the assignors and defendants, the assignee can — and should — allege that to guard against a court sua sponte raising an issue with subject matter jurisdiction midsuit or, worse, after years of litigation. Better yet, an assignee ought to have evidence at its disposal to establish the citizenship of each assignor at the time the action is filed, which is the only date that matters because diversity jurisdiction is determined as of that date.[5] A subsequent change in domicile for an assignor (or any party for that matter) will not defeat existence of diversity.[6] But an assignee should not have just any evidence — it should have evidence that would be admissible under the Federal Rules of Evidence to avoid authentication, hearsay or other admissibility problems. Additionally, an assignee should be able to explain how each piece of evidence supports the diversity analysis. Failure to do so may lead to a court determining it has not been provided with sufficient evidence, which may very well be fatal if the assignee is the one attempting to invoke the diversity jurisdiction as it would bear the burden of establishing subject matter jurisdiction once raised.[7] Should an opponent of assignment raise a Section 1359 challenge to the court's diversity jurisdiction, or if the court questions its subject matter jurisdiction, and the assignee is in the awkward position of not having sufficient information or evidence to make its showing, it ought to request sufficient time to conduct a rigorous investigation into the issues such that it is not in the position of having to rely on representations made on information and belief in the first instance and then later providing contradictory information or, worse yet, evidence. Doing so will not help the assignee's credibility and could raise the specter of sanctions under Rule 11 of the Federal Rules of Civil Procedure. Key Lessons for Nonassignee Opponents Conversely, a nonassignee should investigate any assignment-related allegations or disclosures thoroughly. If the non-assignee has a good faith basis to suspect that diversity jurisdiction exists only as the result of an assignment, then it should alert the federal court to the potential jurisdictional defect. This will force the assignee to provide the court with sufficient, admissible evidence that there was complete diversity at the commencement of the action and avoid an issue raised years later on appeal. If the assignee fails to do so, then the nonassignee ought to detail the deficiencies in the assignee's evidence and explain to the court how the assignee's burden has not been met. A Note on the Presumption of an Invalid Assignment If the district court on remand was unable to analyze whether there was complete diversity between any of Gore's assignor-subcontractors and the defendant (SLSCO) and its surety (Hartford Fire Insurance), that would have been the end of the analysis. However, if the district court determined that there was incomplete diversity between defendants and a particular assignor-subcontractor, then that assignment would have been presumptively ineffective for purposes of Section 1359.[8] While rebutting this presumption is "likely to be difficult," it is incumbent on the assignee-party to prove that it was not made collusively by way of a "credible showing of a legitimate reason for the transfer" that was "unrelated to the fabrication of federal court jurisdiction," according to the U.S. Court of Appeals for the Eighth Circuit's 2004 opinion in McCulloch v. Velez.[9] Given that credibility is in play to rebut this collusion presumption, live testimony likely will be advisable, if not absolutely necessary. Indeed, had the district court turned to the second question on remand, it telegraphed its displeasure with the documentary submission of an email that provided no context for the statements therein despite said email purporting to be evidence of a valid purpose for the assignments. Gore and Assocs. Mgmt. Co. v. SLSCO Ltd., --- F.4th ---, 2025 WL 2938795 (1st Cir. 2025). P.R. Laws Ann. Tit. 22, § 51. BRT Mgmt. LLC v. Malden Storage LLC, 68 F.4th 691, 696 (1st Cir. 2023) (internal quotation marks omitted). Id. Bank One, Texas, N.A. v. Montle, 964 F.2d 48, 49 (1st Cir. 1992). Id. E.g., Woo v. Spackman, 988 F.3d 47, 53 (1st Cir. 2021) (party who asserts jurisdiction bears burden of establishing that it exists by a preponderance of the evidence). McCulloch v. Velez, 364 F.3d 1, 6 (8th Cir. 2004). Id.

November 25, 2025

1st Circ. Offers Diversity Jurisdiction Lessons For Assignees

Law360 Expert Analysis

Practitioners know that in order to bring a diversity action in federal court, the amount in dispute must exceed the statutory minimum and there must be complete diversity of citizenship between the plaintiffs and defendants. Assignments can complicate this analysis because Title 28 of the U.S. Code, Section 1359, provides in relevant part that "[a] district court shall not have jurisdiction of a civil action in which any party, by assignment or otherwise, has been improperly or collusively made ... to invoke the jurisdiction of such court." An Oct. 16 opinion from the U.S. Court of Appeals for the First Circuit in Gore and Associates Management Co. v. SLSCO Ltd. serves as a cautionary tale about what can go wrong — dismissal after years of litigation — if an assignee invoking the jurisdiction of the federal courts has not alleged sufficient facts, or created a sufficient record, to demonstrate there is complete diversity between not only the parties to the action, but also between the putative assignors and parties on the counterparties to the assignee.[1] Background On July 6, 2019, the plaintiff Gore and Associates filed a diversity action in the U.S. District Court for the District of Puerto Rico against the defendant SLSCO and its surety, Hartford Fire Insurance Co., for alleged breach of contract, failure to pay a third-party bond claim, and a payment bond claim under the Puerto Rican Little Miller Act.[2] Specifically, Gore alleged that SLSCO failed to pay invoices submitted by Gore's nonparty subcontractors — Earthwrx LLC, Uniify of Puerto Rico LLC and Uniify Strategic Business Solutions LLC — under several federal contracts related to rebuilding projects in Puerto Rico and the U.S. Virgin Islands after 2017's Hurricane Maria. In the complaint, Gore alleged that its subcontractors assigned their respective rights under the aforementioned invoices to Gore. Preappeal Trial Court Proceedings The defendants moved to dismiss on the ground that the plaintiff's action violated a valid contractual forum selection clause, for failure to state a claim under Rule 12(b)(6) of the Federal Rules of Civil Procedure, and, in the alternative, sought a stay of any surviving claims pending completion of contractually mandated mediation proceedings, but did not challenge the court's subject matter jurisdiction pursuant to Rule 12(b)(1). The trial court dismissed without prejudice certain subcontract-related claims, but refused to dismiss claims under two specific bonds and the Little Miller Act. The district court thereafter instructed Gore to file the dismissed claims in the appropriate forums and return to this case once those claims had been disposed. The case was then stayed. Gore sought reconsideration, leave to amend their complaint and to lift the stay, but the district court denied the requested relief and an appeal followed. Diversity Issue Arises On appeal, the First Circuit sua sponte noted that the while the complaint alleged that Gore was assigned rights by Earthwrx and the Uniify entities, the record did not provide sufficient information to determine whether there was subject matter jurisdiction. As such, the First Circuit ordered the parties to provide supplemental submissions and specifically ordered Gore to provide information about the citizenship of each alleged assignor. The parties complied with the First Circuit's order to file supplemental submissions. Gore posited that the court had adequate diversity jurisdiction. In so contending, it represented that, upon information and belief, Earthwrx was wholly owned by 541 LLC, an Oregon limited liability company with a principal place of business in Oregon. Gore also represented, again upon information and belief, that Uniify of Puerto Rico, a Puerto Rican entity, was wholly owned by Uniify Strategic Business Solutions LLC, a Louisiana company. However, Gore did not submit any evidence to support its position. Unsatisfied, the First Circuit remanded the case for jurisdictional fact-finding, specifically directing the district court to determine: (1) whether each individual subcontractor was completely diverse from the defendants and, if not; (2) whether the assignments to Gore were a collusive attempt to manufacture diversity jurisdiction in violation of Section 1359. Remand Proceedings On remand, the parties agreed to exchange written discovery and reserved the right to take depositions, but no party requested an evidentiary hearing and, instead, they opted to submit simultaneous briefs with accompanying evidence on the jurisdictional issues. In support of the contention that diversity jurisdiction exists for Earthwrx, Gore submitted a certificate of formation, allowing the district court to find that Earthwrx was a Puerto Rican company and James A. Young and Bobby Owens were listed as authorized persons, administrators and members of the LLC. The court determined that none of this information was helpful in assessing whether there was complete diversity between Earthwrx and the defendants. More problematic was that this evidence contradicted Gore's prior submission to the First Circuit that suggested Earthwrx was solely owned by 541 LLC. No documentation was provided to the district court regarding 541 LLC. While Gore did submit some additional public documentation obtained regarding property purchased by Earthwrx's members, it was plainly hearsay and unauthenticated. An email chain was also submitted, but there was no context for the statements therein, even though, according to Gore, its purported purpose was to show that the assignments were to consolidate claims, avoid unnecessary litigation costs and avoid inconsistent judgments. As for the Uniify entities, the court was only able to determine that Uniify was created on Nov. 18, 2017; that Terry Bee was listed as the president, administrator and authorized person for the LLC; and that Uniify Strategic was determined to be an inactive Louisiana LLC that included Bee and Joseph P. Meyer as officers. These findings once again conflicted with Gore's prior position before the First Circuit as it had previously reported that Uniify of Puerto Rico was wholly owned by Uniify Strategic, which, according to the district court, militated against Gore's position. As it had regarding Earthwrx, Gore submitted several additional documents that also ran afoul of the Federal Rules of Evidence in that they were inadmissible hearsay, unauthenticated, unreliable, speculative, inconsistent and simply not helpful to assessing diversity as of the date the action was filed. Outcome Given the foregoing, the U.S. District Court for the District of Puerto Rico was unable to accomplish the First Circuit's remand directive and could not analyze whether there was complete diversity between any of the alleged assignors-subcontractors and defendants — much less turn to the second question of examining the motive behind a particular assignment if there was not complete diversity between any particular assignor-subcontractor and the defendants. The First Circuit held that this was fatal to Gore's suit because it bore the burden of demonstrating the validity of the assignments, as the party seeking to invoke diversity jurisdiction. While Gore sought another remand to conduct additional discovery and seek an evidentiary hearing, the First Circuit refused to do so because Gore had already been given two opportunities to provide evidence of diversity and allowed seven months for the exact purpose of conducting discovery and seeking an evidentiary hearing. The case was dismissed. Key Lessons for Assignees Seeking to Invoke Diversity Jurisdiction If an assignee plans to invoke the diversity jurisdiction of a federal court, it cannot rely solely on the diversity of the parties to the action (if first filed in state court) or eventual action. Instead, the assignee ought to conduct a rigorous investigation into the citizenship of each and every assignor whose rights the assignee is asserting prior to bringing an action. Furthermore, assuming an assignor is an LLC, it is incumbent on the assignee to investigate the citizenship of all members of such entity.[3] If the members of a particular LLC are themselves unincorporated associations, then a deeper, iterative investigation is required; the citizenship of any member must be traced through "however many layers of members or partners there may be," according to the First Circuit's 2023 decision in BRT Management LLC v. Malden Storage LLC.[4] Assuming there is complete diversity of citizenship between the assignors and defendants, the assignee can — and should — allege that to guard against a court sua sponte raising an issue with subject matter jurisdiction midsuit or, worse, after years of litigation. Better yet, an assignee ought to have evidence at its disposal to establish the citizenship of each assignor at the time the action is filed, which is the only date that matters because diversity jurisdiction is determined as of that date.[5] A subsequent change in domicile for an assignor (or any party for that matter) will not defeat existence of diversity.[6] But an assignee should not have just any evidence — it should have evidence that would be admissible under the Federal Rules of Evidence to avoid authentication, hearsay or other admissibility problems. Additionally, an assignee should be able to explain how each piece of evidence supports the diversity analysis. Failure to do so may lead to a court determining it has not been provided with sufficient evidence, which may very well be fatal if the assignee is the one attempting to invoke the diversity jurisdiction as it would bear the burden of establishing subject matter jurisdiction once raised.[7] Should an opponent of assignment raise a Section 1359 challenge to the court's diversity jurisdiction, or if the court questions its subject matter jurisdiction, and the assignee is in the awkward position of not having sufficient information or evidence to make its showing, it ought to request sufficient time to conduct a rigorous investigation into the issues such that it is not in the position of having to rely on representations made on information and belief in the first instance and then later providing contradictory information or, worse yet, evidence. Doing so will not help the assignee's credibility and could raise the specter of sanctions under Rule 11 of the Federal Rules of Civil Procedure. Key Lessons for Nonassignee Opponents Conversely, a nonassignee should investigate any assignment-related allegations or disclosures thoroughly. If the non-assignee has a good faith basis to suspect that diversity jurisdiction exists only as the result of an assignment, then it should alert the federal court to the potential jurisdictional defect. This will force the assignee to provide the court with sufficient, admissible evidence that there was complete diversity at the commencement of the action and avoid an issue raised years later on appeal. If the assignee fails to do so, then the nonassignee ought to detail the deficiencies in the assignee's evidence and explain to the court how the assignee's burden has not been met. A Note on the Presumption of an Invalid Assignment If the district court on remand was unable to analyze whether there was complete diversity between any of Gore's assignor-subcontractors and the defendant (SLSCO) and its surety (Hartford Fire Insurance), that would have been the end of the analysis. However, if the district court determined that there was incomplete diversity between defendants and a particular assignor-subcontractor, then that assignment would have been presumptively ineffective for purposes of Section 1359.[8] While rebutting this presumption is "likely to be difficult," it is incumbent on the assignee-party to prove that it was not made collusively by way of a "credible showing of a legitimate reason for the transfer" that was "unrelated to the fabrication of federal court jurisdiction," according to the U.S. Court of Appeals for the Eighth Circuit's 2004 opinion in McCulloch v. Velez.[9] Given that credibility is in play to rebut this collusion presumption, live testimony likely will be advisable, if not absolutely necessary. Indeed, had the district court turned to the second question on remand, it telegraphed its displeasure with the documentary submission of an email that provided no context for the statements therein despite said email purporting to be evidence of a valid purpose for the assignments. Gore and Assocs. Mgmt. Co. v. SLSCO Ltd., --- F.4th ---, 2025 WL 2938795 (1st Cir. 2025). P.R. Laws Ann. Tit. 22, § 51. BRT Mgmt. LLC v. Malden Storage LLC, 68 F.4th 691, 696 (1st Cir. 2023) (internal quotation marks omitted). Id. Bank One, Texas, N.A. v. Montle, 964 F.2d 48, 49 (1st Cir. 1992). Id. E.g., Woo v. Spackman, 988 F.3d 47, 53 (1st Cir. 2021) (party who asserts jurisdiction bears burden of establishing that it exists by a preponderance of the evidence). McCulloch v. Velez, 364 F.3d 1, 6 (8th Cir. 2004). Id.

News

December 3, 2025

Ray Gauvreau Authors Article on Diversity Jurisdiction

Insurance + Reinsurance group lawyer Ray Gauvreau recently authored an article titled “1st Circ. Offers Diversity Jurisdiction Lessons For Assignees” published in Law360 Expert Analysis on November 25, 2025. In an expansion of his post for the firm’s Covering Appeals blog, Ray discusses an October 16, 2025, opinion from the U.S. Court of Appeals for the First Circuit reminding practitioners that when federal diversity jurisdiction is asserted and a claim has been assigned, an assignee must prove the citizenship of not just itself, but also of every assignor. Failure to do so can be fatal. “If an assignee plans to invoke the diversity jurisdiction of a federal court, it cannot rely solely on the diversity of the parties to the action, or eventual action,” writes Ray. “Instead, the assignee ought to conduct a rigorous investigation into the citizenship of each and every assignor whose rights the assignee is asserting prior to bringing the action.” To read the article, click here.

Law360 Expert Analysis
September 3, 2025

Robinson+Cole Insurance Practice Launches Latest Blog, Covering Appeals

New resource expands firm’s industry insights, unpacking the latest, high-impact insurance coverage appellate cases and trends
Robinson+Cole Insurance Practice Launches Latest Blog, <i>Covering Appeals</i> teaser
August 1, 2024

Robinson+Cole Presents 2024 Awards

December 3, 2025

Ray Gauvreau Authors Article on Diversity Jurisdiction

Insurance + Reinsurance group lawyer Ray Gauvreau recently authored an article titled “1st Circ. Offers Diversity Jurisdiction Lessons For Assignees” published in Law360 Expert Analysis on November 25, 2025. In an expansion of his post for the firm’s Covering Appeals blog, Ray discusses an October 16, 2025, opinion from the U.S. Court of Appeals for the First Circuit reminding practitioners that when federal diversity jurisdiction is asserted and a claim has been assigned, an assignee must prove the citizenship of not just itself, but also of every assignor. Failure to do so can be fatal. “If an assignee plans to invoke the diversity jurisdiction of a federal court, it cannot rely solely on the diversity of the parties to the action, or eventual action,” writes Ray. “Instead, the assignee ought to conduct a rigorous investigation into the citizenship of each and every assignor whose rights the assignee is asserting prior to bringing the action.” To read the article, click here.

Law360 Expert Analysis
September 3, 2025

Robinson+Cole Insurance Practice Launches Latest Blog, Covering Appeals

New resource expands firm’s industry insights, unpacking the latest, high-impact insurance coverage appellate cases and trends
Robinson+Cole Insurance Practice Launches Latest Blog, <i>Covering Appeals</i> teaser
August 1, 2024

Robinson+Cole Presents 2024 Awards

Events

Past

Assignment of Benefits: A Fraudster’s Playground

Mar 23 2026
PLRB 2026 Claims Conference
Past

Stacking Coverage Under UM and UIM Policies: Identifying All Coverages, Preventing Misapplication of Stacking Rules

Sep 6 2022
Strafford webinar
Past

Assignment of Benefits: A Fraudster’s Playground

Mar 23 2026
PLRB 2026 Claims Conference
Past

Stacking Coverage Under UM and UIM Policies: Identifying All Coverages, Preventing Misapplication of Stacking Rules

Sep 6 2022
Strafford webinar

Covering Appeals

Below is an excerpt of the Covering Appeals posts authored by Ray.

A Tale of Two Timelines – Eleventh Circuit Rejects Claimant’s Attempt to Rewrite Occurrence Notice Condition

Occurrence-based liability policies often include a condition that requires the insured, or someone on their behalf, to provide a carrier prompt notice of the occurrence. Delays in reporting a claim can potentially provide a carrier with a late notice defense. The viability of this defense can turn on whether timeliness is evaluated from the perspective of a named insured or a claimant, as a claimant in A.B. v. Barrow, — F.4th —, 2026 WL 40906 (11th Cir. Jan. 7, 2026), found out when the Eleventh Circuit rejected an attempt to rewrite the notice condition to obtain coverage for a $10 million verdict. The Occurrence & Underlying Lawsuits When the claimant/plaintiff, A.B., was ten years old, she was allegedly sexually exploited by her mother and David Barrow in or about late 2013. In February 2018, A.B. filed a lawsuit against Barrow in Alabama alleging that Barrow invaded her privacy. While the privacy invasion action was underway, A.B. filed a separate lawsuit against Barrow and his wife in February 2018 pursuant to the Alabama Fraudulent Transfer Act. During discovery in this suit, A.B., through her attorney, requested a “copy of all insurance policies in force in effect” at the time of the occurrence. On September 25, 2018, it was disclosed that Barrow was insured by Nationwide. A.B.’s attorney thereafter served a subpoena on Nationwide on November 9, 2018, requesting the production of the relevant policies, which were produced in January 2019,  including the operative umbrella liability policy in effect in or about late 2013. The Policy’s “Policy Conditions” section provided: 4. Notice. You or someone on your behalf must: (a) as soon as reasonably possible, give us, our agent or sales representative written notice of an occurrence to which this policy may apply. (b) promptly give us all legal papers or reports relating to the occurrence when a claim or suit is filed against an insured. The policy defined “you” and “your” to mean “the first named insured shown on the Declarations,” which in this case was Barrow. It also defined “occurrence” to include incidents resulting in “personal injury caused by an insured ... during the policy period.” “Personal injury” was defined to include “invasion of rights of privacy.” In July 2019, Nationwide retained counsel to defend Barrow as its insured in the Privacy Invasion Action. The Alabama state court held a bench trial and ruled in favor of A.B. by awarding $4 million in compensatory damages and $6 million in punitive damages, for a total verdict of $10 million. Subsequent Direct Action In July 2022, following the entry of judgment and Barrow’s failure to pay the judgment, A.B. sued Nationwide and Barrow in state court under Alabama’s direct action statute, which permits prevailing plaintiffs to sue the judgment debtor’s insurer directly. Nationwide removed the action to federal court and moved for summary judgment on the ground that “neither Barrow nor A.B. notified Nationwide of its potential duty to indemnify in the time required by the umbrella policy” given the 58-month lapse between Barrow’s conduct (which constituted the occurrence) and the November 2018 subpoena, which the parties agreed constituted constructive notice. The federal district court granted Nationwide’s motion for summary judgment and A.B. appealed to the Eleventh Circuit. Eleventh Circuit Result The Eleventh Circuit first turned to the issue of whether A.B. or her attorney could give Nationwide notice of the alleged occurrence as the parties disagreed whether the service of the subpoena constituted the provision of notice “on [Barrow’s] behalf” under the notice condition of the Policy. Nationwide contended that traditional agency principes define “on behalf of” to mean “as an agent of.” While the Eleventh Circuit agreed that this was the traditional interpretation and that “on behalf of” traditionally meant “for the benefit of,” it noted that the meanings of both phrases have changed such that both phrases are used interchangeably. Given this linguistic evolution as reflected in modern dictionaries and usage guides, the Eleventh Circuit adopted A.B.’s position that she, through her attorney, could give notice on behalf of Barrow as that is the common everyday interpretation. After holding that the language of the Nationwide policy’s notice provision and Alabama law authorize a claimant/injured party or their attorney to give notice to the insurer, the Eleventh Circuit turned to the dispositive late notice issue. Alabama law only permits the consideration of two factors: the length of the delay and the reasons for the delay. Travelers Indem. Co. of Connecticut v. Miller, 86 So. 3d 338, 342 (Ala. 2011). Prejudice is irrelevant. Id. The Eleventh Circuit explained that “[w]hether Nationwide received timely notice under its policy depends on whether [one] evaluate[s] timeliness from the perspective of A.B. as the injured party or instead from the perspective of Barrow as the insured.” From A.B.’s perspective, A.B.’s attorney acted with reasonable promptness under the circumstances.  From Nationwide’s perspective, Barrow, as the insured, was presumed to be familiar with when his own alleged conduct reportedly occurred, as well as the provisions of his policy and nothing in the record suggested that “Barrow did not receive or understand the policy, or that he was otherwise excused from giving notice.” The Eleventh Circuit held that the notice provision was properly interpreted from Nationwide’s perspective, which focused on the insured, because otherwise the disjunctive “or” between “you” or “someone on your behalf” in the Policy’s notice condition would be detached from “the policy’s single timing requirement and create two different notice deadlines.” Put differently, the Policy “allows notice from someone other than Barrow; it does not reset the notice clock for that person.” The Eleventh Circuit further reasoned that if it were to accept A.B.’s alternative interpretation, third-party claimants would “obtain greater rights” than the named insured. Since there was no evidence of any valid excuse for the approximate 58-month delay between late 2013 and November 2018, the Court was “not free to rewrite the contract to reach a different result,” and the grant of summary judgment for Nationwide was affirmed.   Looking Ahead As with any coverage analysis, words and grammar matter. It is therefore important to analyze whether a third party claimant’s – or an insured’s – coverage position is an attempt to rewrite the conditions of the contract. Pointing out such attempts to the court may be persuasive not only in jurisdictions that have strict notice condition analytical requirements, such as Alabama, but also in jurisdictions that require prejudice. It is also important to demonstrate to a court that a third-party claimant (who essentially stands in the shoes of the insured by bringing a direct action) should not have greater rights that the insured themselves as that could render an otherwise valid condition impermissibly written out of a policy.

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Assignees Can’t Collude Their Way Into Federal Court

In Gore and Associates Management Company, Inc. v. SLSCO Ltd., — F.4th —, 2025 WL 2938795 (2025), Plaintiff Gore and Associates Management Company sued Defendant SLSCO Ltd. and its surety, Hartford Fire Insurance Company, as an assignee, for alleged financial losses Gore’s subcontractors (all LLCs) sustained after SLSCO and Hartford Fire allegedly failed to pay for work related to rebuilding projects in Puerto Rico and the Virgin Islands after Hurricane Maria in September 2017. At the outset of the litigation, Gore claimed that the federal courts had diversity jurisdiction over the action. On appeal, the First Circuit sua sponte questioned whether this was so because the plaintiff had alleged in the operative complaint that it was an assignee of three subcontractors’ claims but failed to allege the citizenship information of the assignors and the record did not provide additional information. The parties were asked to submit supplemental briefs on whether the court had diversity jurisdiction. In addition, Gore was specifically ordered to provide information about the citizenships of the assignor subcontractors. Since the subcontractors were alleged to be LLCs, Gore was obligated to provide information about the citizenship of all the members for each assignee. While the parties submitted briefs, Gore did not submit any evidence supporting its position that there was complete diversity. Accordingly, the First Circuit remanded the case to the district court for jurisdictional factfinding that directed the district court to determine: (1) whether the subcontractors were completely diverse from the defendants and, if not; (2) whether the assignments to Gore were a collusive attempt to manufacture diversity jurisdiction in violation of 28 U.S.C. § 1359, which provides that “[a] district court shall not have jurisdiction of a civil action in which any party, by assignment or otherwise, has been improperly or collusively made ... to invoke the jurisdiction of such court.” The Result Upon remand, the parties agreed before the district court to exchange written discovery and reserved the right to take depositions and request an evidentiary hearing—no party sought an evidentiary hearing. Instead, the parties submitted simultaneous briefs to the district court. In a subsequent report issued in September 2025, the district court explained that Gore failed to present sufficient evidence to assess the citizenship of its subcontractor-assignors because it relied on unreliable, speculative, inconsistent documents that were inadmissible (due to lack of authentication and hearsay) under the Federal Rules of Evidence such that the Court could not make adequate factual findings regarding diversity of citizenship much less move to the second question assessing the motive behind the assignments. The First Circuit held that this was fatal to Gore’s suit because it bore the burden of demonstrating the validity of the assignments, as the party seeking to invoke diversity jurisdiction. While Gore sought another remand to conduct additional discovery and seek an evidentiary hearing, the First Circuit refused to do so because Gore had already been given seven months for that purpose. The case was dismissed. Looking Ahead It is important to remember that an assignee of an insurance claim steps into the assignor’s shoes. As such, if an insurer has a good faith basis to suspect that diversity jurisdiction exists only as a result of an assignment, then it should alert the federal court to the potential jurisdictional defect. This will force the assignee to provide the court with sufficient evidence that there is complete diversity and there was no collusion. If an assignee cannot, then that may end a suit close to its inception (or even after it has been fully litigated because there was no federal jurisdiction to begin with). It is also important to recognize that LLCs have the citizenship of all their members, and typically the identity of an LLC’s membership is not publicly known. This should be ascertained or confirmed early in litigation, to avoid a potential problem on appeal years later.

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Welcome to Robinson+Cole’s “Covering Appeals” Blog

Welcome to Robinson+Cole’s Covering Appeals blog, a new resource that analyzes the latest developments in insurance coverage appeals and provides an in-depth analysis of industry trends. Our Insurance Appeals team is known for handling cutting-edge and precedent-setting insurance appeals nationwide, having been involved in key cases arising from the COVID-19 business interruption insurance litigation, Chinese-manufactured Drywall, labor depreciation, September 11th catastrophe, Hurricane Katrina, and various other issues. Our decades of experience with insurance law and the insurance industry enables us to see the big picture. We are pleased to bring you this new blog, which was inspired by our desire to provide clients and the insurance industry with one dynamic resource covering the insurance appeals space. We hope you will subscribe and enjoy our posts.

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Firm Highlights

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Kate Dion and Natale DiNatale Examine the Legal Questions Raised By Sorsby Injunction

Education industry team chair Kathleen Dion and Labor Relations group chair Natale DiNatale discussed the potential ramifications on the NCAA and college athletes in the article, “NCAA to appeal Brendan Sorsby injunction. What it means and how it can win,” published in USA Today, June 8, 2026. Kate pointed out that the injunction is a temporary measure. “This decision is only a preliminary ruling and is subject to appeal. Unless it is overturned, the injunction preserves Sorsby’s opportunity to compete this fall while the underlying case proceeds and allows him to continue preparing for a potential NFL career. For the NCAA, the ruling raises questions about the extent to which courts may review and potentially limit the enforcement of eligibility and competitive-integrity rules in individual cases.”  She continued, “It is also important to recognize that this is one state trial court decision, not a final decision on the merits, and thus its precedential value may be limited. While the court found that Sorsby demonstrated a probable right to the relief that he seeks on his breach of contract and other claims, which is a necessary element for obtaining a temporary injunction — the order does not appear to provide a detailed explanation of the court’s reasoning on that issue. As a result, many of the legal questions raised by the case are likely to remain the subject of further litigation and possible appellate review.” Discussing the foundation of the claim, Natale said, “The underlying dispute looks like a claim that the NCAA failed to accommodate a disability (e.g. an ADA claim based on a gambling addiction). But, it was brought as a breach of contract claim. A contract claim can be brought and maybe kept, in state court, which is likely a friendlier forum for this athlete.” Read the article.

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Robinson+Cole Integrates Thomson Reuters’ Deep Research into Newcode.ai Platform to Advance Secure, Verifiable Legal Research

Robinson+Cole has expanded its firmwide artificial intelligence (AI) capabilities by integrating Thomson Reuters’ Deep Research directly into Newcode.ai, the agentic AI platform implemented last year by the firm to support legal workflows across practices. With this integration, Robinson+Cole is one of only two law firms with direct access to the Deep Research API—and the only firm deploying it through Newcode.ai. Building on its 2025 partnership with Newcode.ai —making Robinson+Cole the first Am Law 200 firm to adopt the platform—the firm has continued to expand its AI capabilities as part of a broader strategy focused on secure deployment, ethical use, and seamless integration into daily legal work. The integration enables Robinson+Cole attorneys to conduct complex, multi‑step legal research and receive verifiable, citation‑backed responses grounded in trusted Thomson Reuters content. By embedding Deep Research into Newcode.ai, Robinson+Cole continues to build on its deliberate, governance‑first approach to AI adoption while delivering meaningful, practice‑ready innovation for its lawyers and clients. “Innovation at Robinson+Cole is grounded in client service, security, and practicality,” said J. Michael Wirvin, Managing Partner of Robinson+Cole. “By incorporating Thomson Reuters’ Deep Research directly into Newcode.ai, we are providing our lawyers with advanced research capabilities in a secure environment fully controlled by the firm that aligns with our standards for data governance, accuracy, and responsible AI use. This integration reflects our continued focus on adopting technology thoughtfully to support our attorneys and deliver value to our clients.” The addition of Deep Research allows attorneys to: Perform sophisticated legal research using agentic workflows that mirror real‑world legal reasoning Receive structured, verifiable responses grounded in Thomson Reuters data Streamline research processes while maintaining rigorous quality and accuracy standards Work entirely within Robinson+Cole’s firm‑controlled AI environment  “Our integration of the Thomson Reuters’ Deep Research API with Newcode represents a defining moment in our AI strategy,” said Chief Data Officer Jim Merrifield. "We are incredibly proud to be the first firm to bring this capability to life—unlocking the power of trusted legal data directly within the workflows our lawyers and business professionals rely on every day. This is exactly how we maximize our technology investments: by connecting best-in-class data sources through APIs into a unified platform, so the technology meets our people where they work, enhances their judgment, and accelerates better outcomes for our clients.” Robinson+Cole’s AI program is guided by firmwide policies, mandatory training, and ongoing oversight to ensure responsible use of emerging technologies. The firm’s approach emphasizes measured adoption, strong information governance, and alignment with client expectations, rather than one‑off experimentation. This latest enhancement underscores Robinson+Cole’s commitment to remaining forward‑thinking in its use of technology, while ensuring that innovation serves the firm’s clients, lawyers, and long‑term strategic goals.

News
Robinson+Cole’s People-First Culture Recognized in Vault’s 2027 Rankings
News
Erica Kerstein Brings Credibility and Business Perspective to New Role as Practice Group Chair

Insurance + Reinsurance group chair Erica J. Kerstein was featured in a Law.com column titled, “How I Made Practice Group Chair,” published on April 15, 2026. In the article, Erica discusses her new role as a practice group chair and how it has expanded her insight into not only the firm’s strategic vision and goals, but the reality of running a business and ensuring that current planning aligns with future goals. “The role provides a window into how individual practices fit into the firm’s overall strategy,” said Erica. “You’re thinking not just about today’s matters, but about where clients are headed, how the industry is changing, and how the firm positions itself to meet those needs.” In addition, Erica also identified “…strengthening client relationships, investing in our people, and staying ahead of emerging issues—particularly around technology and artificial intelligence in the insurance space…” as key priorities for the practice. Read the article.

News
Robinson+Cole Recognized at 2026 Women, Influence & Power in Law Awards
News
Dana Horton Ascends to Presidency of Rhode Island Bar Association
News
Robinson+Cole Expands National Platform with Four Lateral Partners

Robinson+Cole announced the addition of four lateral partners—J. Zachary Balasko, Eric Del Pozo, Brya M. Keilson and Victor R. Salgado, accelerating the firm’s continued investment in the growth of its national bankruptcy and business litigation capabilities. Balasko and Keilson join the firm’s Bankruptcy + Reorganizations group in Washington, DC, and Wilmington, DE, respectively, while Del Pozo and Salgado join the Business Litigation group in Hartford, CT, and Washington, DC. These strategic hires enhance the firm’s ability to serve clients navigating complex, high‑stakes bankruptcy, restructuring, government enforcement, and related litigation matters nationwide and expand the firm’s depth and reach across key markets. “These additions meaningfully reinforce the depth and versatility of our business litigation and restructuring platform and reflect a deliberate approach to strengthening these areas in ways that directly benefit our clients,” said J. Michael Wirvin, the firm’s Managing Partner. “Eric, Zak, Brya, and Victor each bring sophisticated experience and sound judgment that enhance our ability to advise clients through some of their most critical and challenging matters. Their arrival reflects our continued focus on building cohesive, multi-disciplinary teams with capabilities that extend across multiple markets.” J. Zachary Balasko joins the firm as a Bankruptcy + Reorganizations partner based in Washington, DC. His practice focuses on complex Chapter 11 cases and bankruptcy‑related litigation across the country, representing debtors, secured creditors, creditors’ committees, and governmental entities. Balasko brings substantial experience from both private practice and prior service with the U.S. Department of Justice, where he handled major insolvency matters involving federal interests. Eric Del Pozo joins Robinson+Cole’s Hartford, CT office as a Business Litigation partner focusing on complex commercial litigation and appellate matters, representing businesses and public entities in regulated industries in high-stakes and sophisticated disputes. Del Pozo brings experience from senior roles in government and private practice, where he has represented clients at both the trial and appellate levels. Brya Keilson joins Robinson+Cole as a Bankruptcy + Reorganizations partner in the firm’s Wilmington, DE office, one of the nation’s leading venues for complex bankruptcy proceeding . She represents debtors, creditors, committees, trustees, and other parties in interest in sophisticated Chapter 11 and Chapter 7 cases. Keilson is widely experienced in contested bankruptcy matters and frequently advises clients on both strategic and practical considerations throughout the restructuring process. Victor Salgado joins Robinson+Cole as a Business Litigation partner in the firm’s Washington, DC office. He brings significant experience from both government and private practice, including eight years as a federal prosecutor with the U.S. Department of Justice in Washington, DC, where he handled high‑profile and complex cases focusing on public corruption as well as crimes involving financial institutions. Salgado will also work closely with the firm’s Bankruptcy + Reorganizations group on contested matters arising in complex restructurings and related litigation. In addition, Destiney Parker-Thompson joins the firm as a Bankruptcy + Reorganizations associate in the Wilmington office. Parker‑Thompson focuses her practice on bankruptcy, restructuring, and related litigation matters, drawing on experience representing debtors, creditors, and financial institutions in complex Chapter 11 cases. She previously served as a judicial law clerk to the U.S. Bankruptcy Court for the District of Delaware and the U.S. Court of Appeals for the Third Circuit, bringing valuable insight to sophisticated restructuring matters. Robinson+Cole’s Bankruptcy + Reorganizations group has recently been recognized for its role in several of the most complex and precedent‑setting restructuring matters in the country, earning multiple national honors for its work in high‑profile Chapter 11 cases and related litigation. The group has guided stakeholders through landmark proceedings—including award‑recognized reorganizations, a first‑of‑its‑kind bankruptcy confirmed with a Section 524(g) injunction, and other transformative restructurings—reflecting the team’s ability to deliver strategic, results‑driven counsel in matters with significant legal and financial implications.

News
Julianna Charpentier Recognized as an “Up & Coming Lawyer”
News
Robinson+Cole Expands Philadelphia Office at Landmark Liberty Place
News
Robinson+Cole Recognized Across Practices and Regions with 46 Chambers USA 2026 Rankings
News
Kate Dion and Natale DiNatale Examine the Legal Questions Raised By Sorsby Injunction

Education industry team chair Kathleen Dion and Labor Relations group chair Natale DiNatale discussed the potential ramifications on the NCAA and college athletes in the article, “NCAA to appeal Brendan Sorsby injunction. What it means and how it can win,” published in USA Today, June 8, 2026. Kate pointed out that the injunction is a temporary measure. “This decision is only a preliminary ruling and is subject to appeal. Unless it is overturned, the injunction preserves Sorsby’s opportunity to compete this fall while the underlying case proceeds and allows him to continue preparing for a potential NFL career. For the NCAA, the ruling raises questions about the extent to which courts may review and potentially limit the enforcement of eligibility and competitive-integrity rules in individual cases.”  She continued, “It is also important to recognize that this is one state trial court decision, not a final decision on the merits, and thus its precedential value may be limited. While the court found that Sorsby demonstrated a probable right to the relief that he seeks on his breach of contract and other claims, which is a necessary element for obtaining a temporary injunction — the order does not appear to provide a detailed explanation of the court’s reasoning on that issue. As a result, many of the legal questions raised by the case are likely to remain the subject of further litigation and possible appellate review.” Discussing the foundation of the claim, Natale said, “The underlying dispute looks like a claim that the NCAA failed to accommodate a disability (e.g. an ADA claim based on a gambling addiction). But, it was brought as a breach of contract claim. A contract claim can be brought and maybe kept, in state court, which is likely a friendlier forum for this athlete.” Read the article.

News
Robinson+Cole Integrates Thomson Reuters’ Deep Research into Newcode.ai Platform to Advance Secure, Verifiable Legal Research

Robinson+Cole has expanded its firmwide artificial intelligence (AI) capabilities by integrating Thomson Reuters’ Deep Research directly into Newcode.ai, the agentic AI platform implemented last year by the firm to support legal workflows across practices. With this integration, Robinson+Cole is one of only two law firms with direct access to the Deep Research API—and the only firm deploying it through Newcode.ai. Building on its 2025 partnership with Newcode.ai —making Robinson+Cole the first Am Law 200 firm to adopt the platform—the firm has continued to expand its AI capabilities as part of a broader strategy focused on secure deployment, ethical use, and seamless integration into daily legal work. The integration enables Robinson+Cole attorneys to conduct complex, multi‑step legal research and receive verifiable, citation‑backed responses grounded in trusted Thomson Reuters content. By embedding Deep Research into Newcode.ai, Robinson+Cole continues to build on its deliberate, governance‑first approach to AI adoption while delivering meaningful, practice‑ready innovation for its lawyers and clients. “Innovation at Robinson+Cole is grounded in client service, security, and practicality,” said J. Michael Wirvin, Managing Partner of Robinson+Cole. “By incorporating Thomson Reuters’ Deep Research directly into Newcode.ai, we are providing our lawyers with advanced research capabilities in a secure environment fully controlled by the firm that aligns with our standards for data governance, accuracy, and responsible AI use. This integration reflects our continued focus on adopting technology thoughtfully to support our attorneys and deliver value to our clients.” The addition of Deep Research allows attorneys to: Perform sophisticated legal research using agentic workflows that mirror real‑world legal reasoning Receive structured, verifiable responses grounded in Thomson Reuters data Streamline research processes while maintaining rigorous quality and accuracy standards Work entirely within Robinson+Cole’s firm‑controlled AI environment  “Our integration of the Thomson Reuters’ Deep Research API with Newcode represents a defining moment in our AI strategy,” said Chief Data Officer Jim Merrifield. "We are incredibly proud to be the first firm to bring this capability to life—unlocking the power of trusted legal data directly within the workflows our lawyers and business professionals rely on every day. This is exactly how we maximize our technology investments: by connecting best-in-class data sources through APIs into a unified platform, so the technology meets our people where they work, enhances their judgment, and accelerates better outcomes for our clients.” Robinson+Cole’s AI program is guided by firmwide policies, mandatory training, and ongoing oversight to ensure responsible use of emerging technologies. The firm’s approach emphasizes measured adoption, strong information governance, and alignment with client expectations, rather than one‑off experimentation. This latest enhancement underscores Robinson+Cole’s commitment to remaining forward‑thinking in its use of technology, while ensuring that innovation serves the firm’s clients, lawyers, and long‑term strategic goals.

News
Robinson+Cole’s People-First Culture Recognized in Vault’s 2027 Rankings
News
Erica Kerstein Brings Credibility and Business Perspective to New Role as Practice Group Chair

Insurance + Reinsurance group chair Erica J. Kerstein was featured in a Law.com column titled, “How I Made Practice Group Chair,” published on April 15, 2026. In the article, Erica discusses her new role as a practice group chair and how it has expanded her insight into not only the firm’s strategic vision and goals, but the reality of running a business and ensuring that current planning aligns with future goals. “The role provides a window into how individual practices fit into the firm’s overall strategy,” said Erica. “You’re thinking not just about today’s matters, but about where clients are headed, how the industry is changing, and how the firm positions itself to meet those needs.” In addition, Erica also identified “…strengthening client relationships, investing in our people, and staying ahead of emerging issues—particularly around technology and artificial intelligence in the insurance space…” as key priorities for the practice. Read the article.

News
Robinson+Cole Recognized at 2026 Women, Influence & Power in Law Awards
News
Dana Horton Ascends to Presidency of Rhode Island Bar Association
News
Robinson+Cole Expands National Platform with Four Lateral Partners

Robinson+Cole announced the addition of four lateral partners—J. Zachary Balasko, Eric Del Pozo, Brya M. Keilson and Victor R. Salgado, accelerating the firm’s continued investment in the growth of its national bankruptcy and business litigation capabilities. Balasko and Keilson join the firm’s Bankruptcy + Reorganizations group in Washington, DC, and Wilmington, DE, respectively, while Del Pozo and Salgado join the Business Litigation group in Hartford, CT, and Washington, DC. These strategic hires enhance the firm’s ability to serve clients navigating complex, high‑stakes bankruptcy, restructuring, government enforcement, and related litigation matters nationwide and expand the firm’s depth and reach across key markets. “These additions meaningfully reinforce the depth and versatility of our business litigation and restructuring platform and reflect a deliberate approach to strengthening these areas in ways that directly benefit our clients,” said J. Michael Wirvin, the firm’s Managing Partner. “Eric, Zak, Brya, and Victor each bring sophisticated experience and sound judgment that enhance our ability to advise clients through some of their most critical and challenging matters. Their arrival reflects our continued focus on building cohesive, multi-disciplinary teams with capabilities that extend across multiple markets.” J. Zachary Balasko joins the firm as a Bankruptcy + Reorganizations partner based in Washington, DC. His practice focuses on complex Chapter 11 cases and bankruptcy‑related litigation across the country, representing debtors, secured creditors, creditors’ committees, and governmental entities. Balasko brings substantial experience from both private practice and prior service with the U.S. Department of Justice, where he handled major insolvency matters involving federal interests. Eric Del Pozo joins Robinson+Cole’s Hartford, CT office as a Business Litigation partner focusing on complex commercial litigation and appellate matters, representing businesses and public entities in regulated industries in high-stakes and sophisticated disputes. Del Pozo brings experience from senior roles in government and private practice, where he has represented clients at both the trial and appellate levels. Brya Keilson joins Robinson+Cole as a Bankruptcy + Reorganizations partner in the firm’s Wilmington, DE office, one of the nation’s leading venues for complex bankruptcy proceeding . She represents debtors, creditors, committees, trustees, and other parties in interest in sophisticated Chapter 11 and Chapter 7 cases. Keilson is widely experienced in contested bankruptcy matters and frequently advises clients on both strategic and practical considerations throughout the restructuring process. Victor Salgado joins Robinson+Cole as a Business Litigation partner in the firm’s Washington, DC office. He brings significant experience from both government and private practice, including eight years as a federal prosecutor with the U.S. Department of Justice in Washington, DC, where he handled high‑profile and complex cases focusing on public corruption as well as crimes involving financial institutions. Salgado will also work closely with the firm’s Bankruptcy + Reorganizations group on contested matters arising in complex restructurings and related litigation. In addition, Destiney Parker-Thompson joins the firm as a Bankruptcy + Reorganizations associate in the Wilmington office. Parker‑Thompson focuses her practice on bankruptcy, restructuring, and related litigation matters, drawing on experience representing debtors, creditors, and financial institutions in complex Chapter 11 cases. She previously served as a judicial law clerk to the U.S. Bankruptcy Court for the District of Delaware and the U.S. Court of Appeals for the Third Circuit, bringing valuable insight to sophisticated restructuring matters. Robinson+Cole’s Bankruptcy + Reorganizations group has recently been recognized for its role in several of the most complex and precedent‑setting restructuring matters in the country, earning multiple national honors for its work in high‑profile Chapter 11 cases and related litigation. The group has guided stakeholders through landmark proceedings—including award‑recognized reorganizations, a first‑of‑its‑kind bankruptcy confirmed with a Section 524(g) injunction, and other transformative restructurings—reflecting the team’s ability to deliver strategic, results‑driven counsel in matters with significant legal and financial implications.

News
Julianna Charpentier Recognized as an “Up & Coming Lawyer”
News
Robinson+Cole Expands Philadelphia Office at Landmark Liberty Place
News
Robinson+Cole Recognized Across Practices and Regions with 46 Chambers USA 2026 Rankings
News
Kate Dion and Natale DiNatale Examine the Legal Questions Raised By Sorsby Injunction

Education industry team chair Kathleen Dion and Labor Relations group chair Natale DiNatale discussed the potential ramifications on the NCAA and college athletes in the article, “NCAA to appeal Brendan Sorsby injunction. What it means and how it can win,” published in USA Today, June 8, 2026. Kate pointed out that the injunction is a temporary measure. “This decision is only a preliminary ruling and is subject to appeal. Unless it is overturned, the injunction preserves Sorsby’s opportunity to compete this fall while the underlying case proceeds and allows him to continue preparing for a potential NFL career. For the NCAA, the ruling raises questions about the extent to which courts may review and potentially limit the enforcement of eligibility and competitive-integrity rules in individual cases.”  She continued, “It is also important to recognize that this is one state trial court decision, not a final decision on the merits, and thus its precedential value may be limited. While the court found that Sorsby demonstrated a probable right to the relief that he seeks on his breach of contract and other claims, which is a necessary element for obtaining a temporary injunction — the order does not appear to provide a detailed explanation of the court’s reasoning on that issue. As a result, many of the legal questions raised by the case are likely to remain the subject of further litigation and possible appellate review.” Discussing the foundation of the claim, Natale said, “The underlying dispute looks like a claim that the NCAA failed to accommodate a disability (e.g. an ADA claim based on a gambling addiction). But, it was brought as a breach of contract claim. A contract claim can be brought and maybe kept, in state court, which is likely a friendlier forum for this athlete.” Read the article.

News
Robinson+Cole Integrates Thomson Reuters’ Deep Research into Newcode.ai Platform to Advance Secure, Verifiable Legal Research

Robinson+Cole has expanded its firmwide artificial intelligence (AI) capabilities by integrating Thomson Reuters’ Deep Research directly into Newcode.ai, the agentic AI platform implemented last year by the firm to support legal workflows across practices. With this integration, Robinson+Cole is one of only two law firms with direct access to the Deep Research API—and the only firm deploying it through Newcode.ai. Building on its 2025 partnership with Newcode.ai —making Robinson+Cole the first Am Law 200 firm to adopt the platform—the firm has continued to expand its AI capabilities as part of a broader strategy focused on secure deployment, ethical use, and seamless integration into daily legal work. The integration enables Robinson+Cole attorneys to conduct complex, multi‑step legal research and receive verifiable, citation‑backed responses grounded in trusted Thomson Reuters content. By embedding Deep Research into Newcode.ai, Robinson+Cole continues to build on its deliberate, governance‑first approach to AI adoption while delivering meaningful, practice‑ready innovation for its lawyers and clients. “Innovation at Robinson+Cole is grounded in client service, security, and practicality,” said J. Michael Wirvin, Managing Partner of Robinson+Cole. “By incorporating Thomson Reuters’ Deep Research directly into Newcode.ai, we are providing our lawyers with advanced research capabilities in a secure environment fully controlled by the firm that aligns with our standards for data governance, accuracy, and responsible AI use. This integration reflects our continued focus on adopting technology thoughtfully to support our attorneys and deliver value to our clients.” The addition of Deep Research allows attorneys to: Perform sophisticated legal research using agentic workflows that mirror real‑world legal reasoning Receive structured, verifiable responses grounded in Thomson Reuters data Streamline research processes while maintaining rigorous quality and accuracy standards Work entirely within Robinson+Cole’s firm‑controlled AI environment  “Our integration of the Thomson Reuters’ Deep Research API with Newcode represents a defining moment in our AI strategy,” said Chief Data Officer Jim Merrifield. "We are incredibly proud to be the first firm to bring this capability to life—unlocking the power of trusted legal data directly within the workflows our lawyers and business professionals rely on every day. This is exactly how we maximize our technology investments: by connecting best-in-class data sources through APIs into a unified platform, so the technology meets our people where they work, enhances their judgment, and accelerates better outcomes for our clients.” Robinson+Cole’s AI program is guided by firmwide policies, mandatory training, and ongoing oversight to ensure responsible use of emerging technologies. The firm’s approach emphasizes measured adoption, strong information governance, and alignment with client expectations, rather than one‑off experimentation. This latest enhancement underscores Robinson+Cole’s commitment to remaining forward‑thinking in its use of technology, while ensuring that innovation serves the firm’s clients, lawyers, and long‑term strategic goals.

News
Robinson+Cole’s People-First Culture Recognized in Vault’s 2027 Rankings
News
Erica Kerstein Brings Credibility and Business Perspective to New Role as Practice Group Chair

Insurance + Reinsurance group chair Erica J. Kerstein was featured in a Law.com column titled, “How I Made Practice Group Chair,” published on April 15, 2026. In the article, Erica discusses her new role as a practice group chair and how it has expanded her insight into not only the firm’s strategic vision and goals, but the reality of running a business and ensuring that current planning aligns with future goals. “The role provides a window into how individual practices fit into the firm’s overall strategy,” said Erica. “You’re thinking not just about today’s matters, but about where clients are headed, how the industry is changing, and how the firm positions itself to meet those needs.” In addition, Erica also identified “…strengthening client relationships, investing in our people, and staying ahead of emerging issues—particularly around technology and artificial intelligence in the insurance space…” as key priorities for the practice. Read the article.

News
Robinson+Cole Recognized at 2026 Women, Influence & Power in Law Awards
News
Dana Horton Ascends to Presidency of Rhode Island Bar Association